On April 30th, 2025, US Customs and Border Protection (CBP) published clarification on its International Emergency Economic Powers Act (IEEPA) Frequently Asked Questions (FAQ) page regarding import duties for goods in transit.

The FAQ page features a helpful table to be referenced by importers to determine if US import entries qualify for the In-Transit Provision. CBP indicates that it is the importer’s responsibility for confirming if a shipment qualifies under the provision, as well as noting that tariff rates are subject to change. Additionally, CBP stated:

“The in-transit provisions for reciprocal tariffs only apply to the vessel mode of transportation; they do not apply to other modes of transportation such as air, rail, truck, etc. As defined in 19 U.S.C. 1401 and 19 CFR 4.0, vessel includes every description of water craft or other contrivance used or capable of being used as a means of transportation on water, but does not include aircraft. The in-transit provisions do not apply when the shipment begins by vessel and then arrives in the United States using a different final mode of transportation, often referred to as transloading.”

Specifically, the table below provides additional guidance concerning the applicability of the in-transit provisions.

For entries transported other than by vessel that were filed using HTS 9903.01.28, filers should take “immediate action to correct such entries, as necessary, as soon as possible,” CBP said. For those entries that have been filed with CBP erroneously using HTS 9903.01.28, importers or their customs brokers should correct the entry summary by filing a post summary correction. 

Please note that if your shipment has been affected by this clarification, you will be contacted by your RIM representative with further information on processing a Post Summary Correction.

RIM will continue to closely monitor this evolving situation and provide updates as necessary. Please reach out to your RIM representative should you have any further questions.